Cosmetic Product Recall Procedure

cosmetic product recall

Do you know how to responsibly execute a cosmetic product recall? There’s been some buzz recently in the clean beauty space after a well-respected, independent brand discovered that one of its most popular formulas isn’t stable. The development hit the airwaves last week, though the product has been beloved by editors and clean beauty fans from coast to coast for several years. The artisan took to their Instagram account and email list to announce that they’re temporarily halting sales while they investigate and reformulate though they stopped short of declaring a recall. I appreciate that this is a teachable moment for our industry, providing an opportunity  to shed some light on the best cosmetic product recall procedure.

 

How to Responsibly Execute a Cosmetic Product Recall

 

cosmetic product recall

 

A graduate of my cosmetic GMP class put the situation on my radar the day after our graduation, and I found the timing ironic. By way of background: I have both a depth of knowledge and an intense passion for the safety of natural cosmetics and ensuring a bright future for those who are pioneering this space. I spent fifteen years bootstrapping my beauty brand, implementing quality control systems, and building GMP-compliant production protocols. And I walked both the halls of Congress and the corridors of the FDA  for several years, working as a small business advocate to encourage government stakeholders to keep small, independent beauty brands in mind as they craft new federal legislation. As a consultant to makers and product designers, I now teach GMP principles to other beauty brand owners.

 

Product recalls are an unfortunate reality of modern consumerism, and product recall examples are abundant. But there’s a particular cosmetic product recall procedure that needs to be followed.

 

MY CONCERNS WITH THE RECENT SCARE FROM A POPULAR INDIE BEAUTY BRAND

There’s a whirlwind of confusion about the requirements for creation and distribution of personal care products within the United States. I engaged in direct dialogue with this beauty entrepreneur during her announcement and our conversation only deepened my concerns.

  • She elected not to use the word “recall” in any of the announcements that I could locate. That’s a critical keyword for this process and clarity is key.
  • The message to customers included romanticized verbiage like “bloom” and “mild fermentation” rather than clear terms which accurately describe what’s happening with those products: mold and contamination. She later conceded privately that she made “some language mistakes.” While my recommendation for an updated statement with clear language apparently fell on deaf ears, I remain hopeful that she’ll make an additional public statement with clear instructions for her customers.
  • When the brand owner addressed my concerns in the comments section of her Instagram post, she mentioned that she’d sold tens of thousands of units of this particular product over the years and affirmed that it “has always challenge tested stable.” She later reached out to me privately and said that the company was “undergoing challenge testing for all of [their] formulas as required by the EU regulatory system.” Those statements are contradictory and lead me to wonder if she understands the nature of these tests and when/why they’re required.
  • When customers inquired on Instagram about whether the product in their possession was safe to use, the company expressed that continued use was “at their discretion.” Both those who hadn’t noticed mold and those who spoke of scraping the mold off the tops of their face mask received that same information. *shudder*  This approach jeopardizes the health of customers while exposing the company to legal liability that’s simply not worth the cost of saving face.

 

BALANCING OUR DESIRE FOR NATURAL BEAUTY WITH THE PUBLIC’S NEED FOR SAFETY

 

Cosmetic Product Recall Procedure

 

Over the past few years, a host of bad actors have invited unwelcome attention and a sense of hysteria about cosmetic safety. I’m looking at you Claire’s, WEN by Chaz Dean, and Brazilian Blowout.

 

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Review of Faire- The Wholesale Marketplace Platform

review of Faire

It’s the platform every maker and buyer is talking about, and I’m here to share my final review of Faire. Over the last few months, I’ve been exploring the Faire wholesale marketplace (formerly Indigo Fair) to help my community determine if they should apply to sell on the platform. The blog series has grown in size and scope as I dug deeper and deeper into the review of Indigo Fair/ Faire and analyzed the pros and cons of this emerging wholesale marketplace.

 

Review of Faire

I’m back with the seventh (!) and final installment of this series to share community reactions and my final thoughts regarding selling on Faire.

 

Faire Final Thoughts_2

 

HOW DO PEOPLE FEEL ABOUT FAIRE?

Over four weeks, I invited both artisans and buyers who had experience with Faire to take part in a survey to collect feedback from this community and measure the results makers see on the platform. I received 91 responses: 83% of those were from artisans, 9% were from retailers, and 8% of respondents both bought and sold on Faire. You’ll note that I’ve summarized the findings of this survey in an infographic at the end of this post.

 

The majority of respondents have been selling on Faire for less than three months (39%). Another 34% have been on the wholesale marketplace for between 3-6 months, and just 3% have been on Faire for eighteen months or more.  I asked those who completed the survey two key questions…

 

  1. On a scale of 1-100, how pleased are you with your experience with Faire? The average answer was 72.
  2. On a scale of 1-100, how would you rate Faire’s responsiveness and customer service? The average score was 79.

 

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I was keenly interested in hearing directly from brand owners about the volume of orders on Faire. The vast majority (47%) receive between 1-4 orders per month. Another 29% of respondents receive between 5-9 orders per month, which means that 76% of all artisans on Faire receive nine orders or less per month. Interestingly, 1% of respondents receive 50+ orders per month!

 

Exactly half of all respondents (50%) received their first order on Faire within one week of going live on the platform.  That’s quite impressive, and it’s easy to see why makers get hooked on Faire/ Indigo Fair so quickly. In total, 88% of Faire sellers closed an order within their first month, and just 2% are still waiting on their first order. That healthy dose of instant gratification makes me wonder if Faire tinkers with their algorithms to quickly deliver orders to new brands for the benefit of “seeding” the relationship.

 

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An Interview with Max Rhodes, CEO of Faire

Interview with Max Rhodes

An Interview with Max Rhodes, CEO of Faire

 

Over the last few months, I’ve been exploring the Faire wholesale marketplace (formerly Indigo Fair) in an effort to help readers determine if Faire is right for you. In an interview with Max Rhodes, the CEO of Faire, I invited him to the table to respond directly to some of my findings and the feedback gathered from the artisan community. I’m honored that he took me up on the offer and I’m eager to share our conversation about the pros and cons of Faire, alongside Max’s thoughts about the evolution of the wholesale landscape.

 

I’ve published Max’s responses in their entirety without editing.

 

faire interview_max rhodes

 

LELA: What does Faire look for in a maker? What factors do you consider when reviewing a brand’s application?

MAX RHODES: We carefully evaluate each maker that applies to join Faire, and there are several factors that we look at to determine which to accept. Among those are the number of stockists they are currently carried in, the category and quality of products, and their overall brand aesthetic. When appropriate, we will also cross reference a brand’s social media presence to gauge how well their products might sell on our marketplace.

 

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LELA: How does Faire vet potential buyers on the platform?

MAX RHODES: Like makers that apply, we also review every retailer to make sure they are a good fit for our marketplace. We fully vet each retailer to confirm that they are legitimate retailers, meaning that they must actually sell goods, ideally in a brick and mortar environment. There’s no shortage of fraud in ecommerce, so we have a team dedicated to making sure that doesn’t infiltrate Faire.

 

LELA: What can you share about the algorithm that predicts a brand’s visibility on the Faire platform? What factors into that algorithm and how can makers maximize their visibility?

MAX RHODES: The recommendations that retailers get are informed by a variety of factors, including: the type of retailer they are, their profile and products, the kind of items they have historically purchased, and conversion rates for a given brand (in other words, whether or not retailers are ordering once they visit a brand’s page and if those items are being returned or not). The recommendations can vary greatly by retailer because they are curated and catered specifically to their business needs.

 

 

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LELA: One maker I spoke with raised a concern about tax ID numbers as it relates to her responsibility to collect sales tax. Her concern was that if she’s ever audited by the state, she’ll need to produce the resale certificates from her in-state retailers that prove that those sales were exempted from sales tax. If she fails to do so, then she can be held responsible for not having collected the appropriate tax, leaving her to settle the bill and any related penalties.

As I understand it, artisans don’t have access to that information about their retailers via Faire. How would you instruct her to handle that? Could a Faire artisan contact Faire representatives if they were under audit and gain access to the necessary certificates to absolve them of any tax liability?

MAX RHODES:  Faire is a reseller and all purchases made by it from any Faire.com wholesaler are for resale on its platform and therefore should not be subject to sales tax. Faire exercises commercially reasonable efforts to ensure that any goods sold on its platform are purchased by resellers for resale in their ordinary course of business. As such, sellers should not incur any sales tax liability for sales made on the Faire.com platform. We encourage any maker who is in need of assistance regarding a tax related inquiry to contact Faire’s customer support team.

 

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The Disadvantages of Faire

disadvantages of faire

Over the last several weeks, I’ve been exploring the potential pros and cons of Faire (formerly Indigo Fair) here on the Lucky Break blog. Today I’m sharing some of the disadvantages as part of an ongoing blog series about emerging wholesale marketplaces. While there’s certainly a lot to love about working with this wholesale platform for artisans, there are notable disadvantages of Faire, too. I shared a few of those disadvantages in a previous blog, and I’m back with additional thoughts to help you determine if Faire is the right opportunity for your brand.

 

The Disadvantages of Faire

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I’m pleased to share that Max Rhodes, Faire’s CEO, graciously provided answers to a tidy list of queries I sent his way. In the final two blogs of this series, I’ll share his responses, my final thoughts, and the results of the Lucky Break community survey.

 

FAIRE FAVORS BUYERS ABOVE BRANDS

There’s a general feeling among many makers and product designers that retailers are getting the better deal when it comes to Faire. They enjoy generous ordering incentives, including free shipping, free returns on first orders from any brand, and $200 cash to spend when signing up through a brand’s Faire link.

 

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However, artisans often believe that they’re getting the shorter end of the stick. We’re enjoying an increase in exposure, but we’re also paying a princely sum (up to 28% of the order) for the privilege of being seen. Thankfully, we’re not saddled with the burden of product returns, though passing the baton to Faire on that front creates separate issues that are worth exploring.

 

SLUGGISH CUSTOMER SERVICE

I frequently hear criticism about slow responses from the Faire team, especially as it pertains to reviewing applications for new makers. Despite those rumbles of frustration, artisan satisfaction with Faire’s customer support team appears to increase exponentially once we gain acceptance onto the platform.

 

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What makers, designers and retail buyers love about Faire

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As part of my ongoing blog series about emerging wholesale marketplaces, I’m highlighting the benefits of Faire (formerly Indigo Fair). And there’s certainly a lot to love about working with this wholesale platform for artisans, from the perspectives of both a maker and a retailer. Faire has ambitiously harnessed technology to create advantages for all stakeholders in the world of wholesale, and I’m excited to dive in and share them with you.

 

WHAT ARTISANS LOVE ABOUT FAIRE

 

Product designers who set up shop on Faire praise the passive nature of the platform and the increased visibility among buyers. The application process is simple, the Faire team takes care of the onboarding logistics, and makers often enjoy an order within the first week. Because Faire charges no upfront fees, the marketplace involves little risk on behalf of the artisan. That’s a welcome relief to brand owners who’ve traditionally gambled thousands of dollars brands to exhibit at a single trade show.

 

Creative entrepreneurs often spend a sizable amount of time reaching out to stores off interest, never sure whether a specific buyer will appreciate their work or have the budget necessary to bring on new lines. Faire buyers shop at their convenience, which eliminates the guesswork for brands. If a boutique owner is on the Faire site, then they’re on the prowl for new products. Even when they aren’t present, brand owners are investing their energy into the 783 other facets of running a company that demand their daily attention.

 

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Faire has gathered eyeballs and buying power at record speed. As of early February 2019, the platform had vetted 19,271 retailers according to a post within their official Facebook community. That potential for exposure often translates to a respectable volume of orders, which helps to offset the higher-than-average commission structure. Brands currently pay as much as 28% of an opening order in fees on Faire.

 

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